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October 2018 www.SecurityInfoWatch.com / Security Dealer & Integrator 49
as an autodialer, as used in the TCPA; as well as how to define
the called party for calls to a number that has been reassigned
to a new customer.
Consumer advocates support a broad definition of an
autodialer. They also support defining the called party as the
party actually reached by a call. Business commenters sup-
port a narrow reading of the definition of autodialer, arguing
that the called party should be the party the caller intends
to reach.
The AICC filed reply comments in this proceeding and
urged the FCC to reject a broad interpretation of the defini-
tion of autodialer to ensure customers are able to receive crit-
ical messages and notifications regarding their alarm systems.
The AICC also argued that the term "called party" should refer
to the party the caller intends to reach.
In support of its position, the AICC explained that when a
monitoring company receives notification of a smoke or fire
alarm, emergency personnel are dispatched immediately and
the monitoring station attempts to contact the customer.
Alarm customers provide contact numbers – both their own
and the numbers of others, which could be a wireless number
– for this purpose.
Alarm systems also may send notifications when devices
are added or deleted; and system trouble notifications, such
as a device going offline, a device with low battery power,
a system AC power failure, or a user locked out after failed
sign-in attempts, that are critical to the safety of the subscriber.
For example, a device going offline may be because a home
intruder has removed the alarm device. A signal that a user is
locked out after failed attempts to sign in may be because an
unauthorized person and/or intruder is trying to sign in to the
system. Without power, the system will not work as desired by
the customer to protect life and property.
When these types of signals are received by the alarm moni-
toring station, it will contact the customer. If the customer can-
not be contacted, the central station will contact the alterna-
tive contact person(s) provided by the customer.
Besides these emergency communications, alarm compa-
nies also place automated calls that are closely related to the
purchased alarm service, and are the type of communications
customers expect to receive by providing their cell phone num-
ber to an alarm company. A broad interpretation of autodialer
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